This policy applies to the collection, use, disclosure and management of personal information by Credit Canada Debt Solutions (CCDS).
The Program Director of CCDS is accountable for compliance with these policies and procedures regarding the manner in which CCDS collects, uses, discloses and otherwise manages personal information.
The Program Director is appointed as the Privacy Officer for CCDS.
CCDS is responsible for personal information in its custody and control.
2. Identifying the Purposes for Collecting and Using Personal Information
CCDS collects and uses personal information to provide advice and information on personal money management issues and to provide advice, information and options for debt repayment to CCDS clients by dealing with their various creditors. The personal information collected by CCDS includes information on clients' debts, income, assets, living expenses, employment situation, general financial status and their relationships with various creditors.
CCDS also uses the aggregate demographic information from the personal information collected to identify services and programs that may benefit the communities we serve; to target our marketing and awareness programs; and to maintain the ongoing financial support and cooperation of our stakeholders. No individual can be identified through this information.
CCDS personnel are trained to explain the purposes of collecting the information to any client who asks for an explanation. The purpose for which personal information is collected and used by CCDS personnel is communicated to each client at or prior to the time of collection.
3. Getting the Client's Consent
CCDS will not collect, use or disclose a client's personal information without the express consent of the client.
4. Limits for Collecting Personal Information
CCDS personnel collect personal information about individuals only where such individual is a client or potential client of CCDS. Our clients' personal information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law.
5. Limits for Disclosing Information Related to Debt Consolidation Programs
All information provided to CCDS related to our Debt Consolidation Programs (DCPs) is kept strictly confidential and is protected in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). CCDS will not release any information regarding clients' files without obtaining their written authorization (unless required by law). This includes personal information as defined in PIPEDA.
6. Limits for Disclosing and Retaining Personal Information
CCDS discloses personal information only for the purposes for which it was collected. It keeps information for as long as it is required for the stated purposes.
CCDS retention policy provides that files regarding Debt Consolidation Programs (DCPs) are retained for a maximum of 7 years from the date the DCP is closed, after which time the files are permanently destroyed.
CCDS retention policy provides that files regarding financial counselling only sessions are retained for a maximum of 7 years from the date of the last counselling session, after which time the files are permanently destroyed.
Personal information that is no longer required to fulfill the identified purposes or that is not required to be retained pursuant to any applicable law is destroyed, erased or made anonymous. CCDS reviews the personal information in its custody and control on a periodic basis in order to ensure that personal information no longer required to be retained has been destroyed, erased or made anonymous.
7. Keeping Personal Information Accurate
CCDS ensures, to the best of its ability, that the information it holds is accurate, complete, current and relevant to the identified purposes.
CCDS maintains a strict confidentiality agreement with those who have access to the personal information being held by CCDS. Any corrections to the information can be given to those parties. CCDS recognizes that it is crucial that creditors of its clients have current and accurate information in order to make important decisions regarding the acceptance of our client Debt Consolidation Programs as well as other credit decisions.
8. Safeguarding Personal Information
CCDS ensures that personal information is stored in electronic and physical files that are physically secure. Security measures include storage of files in locked filing facilities when not in use; secure locks on the offices of CCDS and its satellite offices. Electronic files are protected by encryption software. Staff passwords to access such electronic files are controlled and employ high-level encryption practices.
Distribution of personal information regarding clients is restricted to the employees of CCDS and any creditors for whom a Debt Consolidation Program is entered into in respect of CCDS clients.
The employees of CCDS sign a Confidentiality Agreement and will abide by these privacy policies and procedures.
Physical CCDS files containing personal information are shredded under the supervision of CCDS employees. Deleted electronic files will be permanently removed from the system, as discussed in section five (5).
9. Individual Access to Personal Information
Upon written request, CCDS will provide an individual with confirmation as to whether CCDS has personal information about them, what the information is, what it is being used for and to whom the information has been disclosed.
Individuals should send their written request for access, with contact information and enough information about themselves to identify them to the Executive Director of CCDS.
CCDS will respond within thirty (30) days of receiving any access request at no cost to the individual.
If the individual can provide proof of an error in the personal information held by CCDS, then CCDS will amend the information and where appropriate, send the corrected information to others who have used the incorrect information.
If CCDS denies the individual's request for access, it will state the reasons for denial.
10. Handling Individual Complaints and Questions
Individuals may send any complaints regarding CCDS's compliance with its own privacy policies and procedures to the Program Director of CCDS. The Program Director or designated staff will investigate the complaint and respond to the individual.
If the individual's complaint is justified, CCDS will change its policies and procedures related to the matter so that other individuals will not experience the same problem.